Latest / The Privacy Partnership Podcast with Robert Bateman
New EDPB guidance: When to issue a GDPR fine
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How does a data protection regulator decide whether to hand down a multi-million euro fine or issue a simple reprimand? In this episode, Robert Bateman breaks down the European Data Protection Board’s (EDPB) newly published draft Guidelines 04/2026. Adopted for public consultation on 17 September 2026, these guidelines replace the 2017 Article 29 Working Party guidance and aim to heavily harmonise the enforcement playbook across Europe.
We explore how the EDPB has baked recent CJEU case law directly into a new, five-step methodology that regulators will use to determine the…
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